In the second quarter of fiscal 2021 and 2020, we recognized income tax expense of $80.7 million and $84.1 million, respectively. In the first half of fiscal 2021 and 2020, we recognized income tax expense of $167.4 million and $72.6 million, respectively. The effective tax rate (calculated as the ratio of income tax expense to pre-tax income, inclusive of equity method investment earnings) was 17.6% and 24.3% for the second quarter of fiscal 2021 and 2020, respectively. The effective tax rate for the first half of fiscal 2021 and 2020 was 19.1% and 14.3%, respectively.

The effective tax rate in the second quarter of fiscal 2021 reflected a release of valuation allowance associated with the expected capital gains from the planned divestiture of the Peter Pan^® peanut butter business and a benefit from statute lapses on tax issues that were previously reserved.

The effective tax rate for the first half of fiscal 2021 reflects the above-cited items, as well as a benefit resulting from the regulations issued by the U.S. Treasury and Internal Revenue Service on certain provisions of the 2017 Tax Cuts and Jobs Act.

The effective tax rate in the second quarter of fiscal 2020 reflected the following:

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additional tax expense primarily associated with non-deductible goodwill in our Lender's^® bagel business, for which an impairment charge was recognized,

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a benefit from statute lapses on tax issues that were previously reserved for, and

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an income tax benefit associated with a deduction of a prior year federal income tax matter.

The effective tax rate for the first half of fiscal 2020 reflected the above-cited items, as well as the impact of benefits from the settlement of tax issues that were previously reserved, a change in deferred state tax rates due to the integration of Pinnacle activity for tax purposes, a tax planning strategy that will allow utilization of certain state attributes, and state tax law changes.

The amount of gross unrecognized tax benefits for uncertain tax positions was $33.9 million as of November 29, 2020 and $35.8 million as of May 31, 2020. Included in those amounts was $0.8 million and $0.7 million, respectively, for tax positions for which the ultimate deductibility is highly certain but for which there is uncertainty about the timing of such deductibility. The gross unrecognized tax benefits excluded related liabilities for gross interest and penalties of $8.1 million and $7.4 million as of November 29, 2020 and May 31, 2020, respectively.

The net amount of unrecognized tax benefits at November 29, 2020 and May 31, 2020 that, if recognized, would impact the Company's effective tax rate was $28.8 million and $30.3 million, respectively. Included in those amounts is $6.5 million that would be reported in discontinued operations. Recognition of these tax benefits would have a favorable impact on the Company's effective tax rate.

We estimate that it is reasonably possible that the amount of gross unrecognized tax benefits will decrease by up to $12.1 million over the next twelve months due to various federal, state, and foreign audit settlements and the expiration of statutes of limitations.

As of November 29, 2020 and May 31, 2020, we had a deferred tax asset of $685.3 million and $685.2 million, respectively, that was generated from the capital loss realized on the sale of the Private Brands operations with corresponding valuation allowances of $660.0 million and $685.2 million, respectively, to reflect the uncertainty regarding the ultimate realization of the tax asset. Federal capital loss carryforwards related to the Private Brands divestiture will expire in fiscal 2021.

We have not provided any deferred taxes on undistributed earnings of our foreign subsidiaries. Deferred taxes will be provided for earnings of non-U.S. affiliates and associated companies when we determine that such earnings are no longer indefinitely reinvested and will result in a tax liability upon distribution.